- 14 - available under either subsection. See Washington v. Commissioner, 120 T.C. 137, 146-147 (2003); see also Hopkins v. Commissioner, 121 T.C. 73, 88 (2003); Block v. Commissioner, supra. When petitioner and Levy filed their joint returns for 1991 through 1999, they did not remit payment of the reported balance due on those returns. Petitioner thus acknowledges she does not qualify for relief under section 6015(b) or (c) for the years 1991 through 1999, since there is no deficiency but rather an underpayment in tax for each of those years. See, e.g., Washington v. Commissioner, supra at 146-147. The parties agree that for 1979 (unlike 1991 through 1999) there is a deficiency, joint liability for which petitioner is seeking relief under section 6015(b) or (c). A. Relief Under Section 6015(b) for 1979 Section 6015(b)(1) provides: SEC. 6015. RELIEF FROM JOINT AND SEVERAL LIABILITY ON JOINT RETURN (b) Procedures for Relief From Liability Applicable to All Joint Filers.-- (1) In general.--Under procedures prescribed by the Secretary, if–- (A) a joint return has been made for a taxable year; (B) on such return there is an understatement of tax attributable toPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011